Datalign Advisory, LLC

Client Privacy Policy

Effective: December 21, 2021

Our Commitment to You

Datalign Advisory, LLC (“Datalign”) is committed to safeguarding the use of your personal information that we have as your Investment Advisor. Datalign (referred to as "we", "our" and "us" throughout this notice) protect the security and confidentiality of the personal information we have and make efforts to ensure that such information is used for proper business purposes in connection with the management or servicing of your account. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust.

We do not sell your nonpublic personal information to anyone. Nor does Datalign provide such information to others except for discrete and proper business purposes in connection with the servicing and management of your account as discussed below.

Details of our approach to privacy and how your personal nonpublic information is collected and used are set forth in this privacy policy. 

The Information We Collect About You

You typically provide personal information when you complete the paperwork required to become our Client. This information may include your:

•   Name and address
•   E-mail address
•   Phone number
•   Social security or taxpayer identification number

In addition, we may collect nonpublic information about you from the following sources:

  • Information we receive in the course of establishing a customer relationship including, but not limited to, applications, forms, and questionnaires.
  • Information about your transactions with us or others.

 Information about You That Datalign Shares

Datalign works to provide products and services that benefit our customers. We may share nonpublic personal information with non-affiliated third parties as necessary for us to provide agreed services and products to you consistent with applicable law. We may also disclose nonpublic personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with our services to you. In addition, your nonpublic personal information may also be disclosed to persons we believe to be your authorized agent or representative, regulators in order to satisfy Datalign’s regulatory obligations, and as is otherwise required or permitted by law.  Lastly, we may disclose your nonpublic personal information to companies we hire to help administrate our business. Companies we hire to provide services of this kind are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested.

To repeat, we do not sell your nonpublic personal information to anyone.

Information about Former Investors

Datalign does not disclose, and does not intend to disclose, nonpublic personal information to non-affiliated third parties with respect to persons who are no longer our clients.

Confidentiality and Security

Our employees are advised about the firm's need to respect the confidentiality of our customers' nonpublic personal information. Additionally, we maintain physical, procedural and electronic safeguards in an effort to protect the information from access by unauthorized parties.

 We'll keep you Informed

We will send you notice of our privacy policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise our privacy policy, and will provide you with a revised policy if the changes materially alter the previous privacy policy. We will not, however, revise our privacy policy to permit the sharing of nonpublic personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. You may obtain a copy of our current privacy policy by contacting us at (781) 228-5678.

DatalignAdvisory.com

This site privacy policy (“Privacy Policy”) explains how datalignadvisory.com collects, uses, shares and safeguards information about you when you use the datalignadvisory.com website and any associated content and materials available in connection with the website (collectively, the “Site”).

By using the Site, you agree to the collection, use and disclosure of your information as described in this Privacy Policy.   If you do not agree to this Privacy Policy, you should not use or provide any information via the Site.  We reserve the right to make changes to this Privacy Policy at any time and for any reason.  Any changes will be reflected in a revised policy posted on the Site and we will alert you that there has been a change by updating the “Revised” date displayed on the Privacy Policy.  You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date on which such revised Privacy Policy is posted.

  1. Collecting Your Information. We may collect information about you in a variety of ways.  The types of information we may collect via the Site include, but are not limited to:
  • Demographic and other personal information you choose to provide in connection with completing an online form, providing content on the Site, or other activities in which you participate on the Site, such as your name, age, phone number, location and financial information.
  • If you arrive at the Site by “clicking through” from an email or other website, certain information about you that you provided to that email sender or other website, such as the terms you were searching that led you to the Site.
  • Information our servers automatically collect when you visit, use, or browse the Site, such as your IP address, your operating system, browser version, the address of a referring website, the pages you visit on the Site, the dates and times you visit the Site, device and usage information, such as language preferences, referring URLs, country, location, information about how and when you use our services and other technical information. This information is primarily needed to maintain the security and operation of our services, and for our internal analytics and reporting purposes.
  • Information collected via the use of cookies, web beacons and other tracking technology, as further discussed below
  • If you access the Site from a mobile device, information about the type of mobile device you use.
  • Information about you from third party sources that we contract with for the purpose of verifying the contact information you provided to the Site and other third parties, including data aggregators and public databases.
  1. Using Your Information. We may use any information collected about you via the Site to: help increase the efficiency and operation of the Site; deliver and improve our products and services; manage our business; monitor and analyze usage and trends to improve the Site and the user experience; generate a personal profile of you to make future visits to the Site more personalized; perform the functions and services you request; send you confirmations, updates, alerts, administrative messages, and otherwise facilitate your use of the Site; request feedback and contact you about your use of the Site; respond to your emails; compile anonymous statistical information and analyses, which we may use internally and/or provide to third parties; and deliver information to you that you request or that we think may be of interest to you, such as articles, news, or information about various promotions.
  2. Sharing Your Information. We may share your information as follows:
  • We may share your information with third parties that perform services for or on our behalf.
  • We may share your information as permitted or required by any applicable law in response to a subpoena or other legal process or as we deem necessary to investigate or remedy any actual or potential violation of our policies or to protect the rights, property, and safety of datalignadvisory.com or others, as we deem appropriate.
  • We may allow selected third parties to use tracking technology on the Site, which will enable them to collect information about how you use the Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.
  • If we reorganize or otherwise transfer some or all of the Site or our assets to another organization (such as in the course of a merger, dissolution, liquidation), your information may be shared with the transferee; however, we will ask the transferee to honor commitments we made in this Privacy Policy.
  1. Security of Your Information. While we take reasonable steps to protect any personally identifiable information you choose to provide via the Site  from unauthorized access, please be aware that, despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse.  Any information disclosed online can potentially be intercepted and used by unauthorized parties, so please keep this in mind when disclosing any personal or personally identifiable information via the Site.  To help ensure security via the Internet, we recommend you keep your browser up to date with automatic security updates enabled.
  2. Cookies and Tracking Technology. The Site may use cookies, web beacons, and other tracking technology depending on the features offered. Tracking technology is useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help us customize the Site and improve your experience. When you browse the Site, your personally identifiable information is not collected through the use of cookies.  However, if you previously provided personally identifiable information to us, a unique identifier in the cookie may tie the information collected via the cookie to such information.  Aggregate cookie and tracking information that does not directly identify you may be shared with third parties.  Also, some content on the Site may be provided by third parties that may use cookies in conjunction with other tracking technologies to collect information about you when you use the Site, which enables them to provide targeted advertising to you.  We do not control these third parties’ tracking technologies or how they may be used.  We may display certain advertising offers on the Site or allow service providers, advertisers, ad networks, or other third parties to advertise on the Site.  Additionally, we may use third party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives.  This third party software may use cookies, web beacons, or similar tracking technology to help manage and optimize your online experience with us. Most web browsers are set to accept cookies by default.  You can usually choose to set your browser to disable or reject cookies.  Be aware that disabling or rejecting cookies could affect the availability and functionality of the Site or certain portions of the Site.  Also, please note that we may still use information we’ve collected from cookies prior to your disabling them; however, we will not collect any further information from the disabled cookies.
  3. Policy for Children. We do not use the Site to solicit information from or market to children under the age of 18.  By using the Site, you represent that you are at least 18 years of age.  We encourage parents and legal guardians to monitor their children’s internet usage and to instruct their children to never provide personal information through the Site or any other website without parental consent.  If you believe a child has provided personal information to us via the Site, please contact us and we will use reasonable efforts to locate and delete the information.
  4. Links to Other Websites and Third Party Practices. The Site may contain links to third party websites.  It is our intent to provide links only to other quality websites.  However, we have no control over these linked websites or, for that matter, any third parties.  Any information collected by websites, other than the Site, is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites that may be linked to or from the Site.  We encourage you to read the provisions of privacy policies on other websites before providing them with your personal information.
  5. California Consumer Privacy Act Notice

The California Consumer Privacy Act (“CCPA”), which provides California Consumers certain rights regarding their Personal Information (“PI”) as those terms are defined in the CCPA, became effective on January 1, 2020. As of that date, the California Attorney General had not completed the rule making process to establish the regulations for businesses to implement the law.

In the meantime, we are providing you with notice of the personal information we collect and our purposes for that collection for data that may be subject to the CCPA (“CCPA Notice”). This CCPA Notice does not cover information that is outside of the scope of the CCPA. This notice also does not apply to data collected from employees, applicants or contractors or to data collected from individuals acting as representatives of another business in connection with business communications or transactions.

We may collect and share the following personal information that may be subject to the CCPA for the following purposes:

Category of PIPurposes for CollectionCategories of Third Parties with whom PI is shared
1. Identifiers and Personal Records
(e.g., name, phone number, e-mail address, IP address)
Providing our services, improving our services, quality assurance, marketing, security, internal analytics and reportingVendors, data analytics partners, advertising partners
2. Internet Usage Information (e.g. information regarding your interaction with our services)Security, internal analytics and reportingVendors, data analytics partners, advertising partners
3. Geolocation DataSecurity, internal analytics and reportingVendors, data analytics partners, advertising partners
4. Inferences from PI Collected (e.g. your preferences, your likelihood of interest in certain of our services)Providing our services, improving our services, marketingVendors, data analytics partners, advertising partners

In addition, we may collect, use, and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.

We do not knowingly “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request.

California Consumers have the right to exercise the privacy rights under the CCPA. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI.

We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

If you are a California Consumer and would like to register a request under your “right to know about personal information collected, disclosed or sold” (including right to obtain copies of specific pieces and/or information about categories of personal information practices), “right to request deletion of personal information,” or “right to opt-out of the sale of personal information,” or otherwise exercise any of your other privacy rights under the CCPA, you can contact us at privacy@datalignadvisory.com and we will respond to your request as and when we have regulatory guidance on how to properly verify you and respond to your requests and are able to do so.

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

  • The categories of PI we have collected about you.
  • The categories of sources from which we collected your PI.
  • The business or commercial purposes for our collecting or selling your PI.
  • The categories of third parties with whom we have shared your PI.
  • The specific pieces of PI we have collected about you.
  • A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
  • A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:
    • The categories of your PI we have sold.
    • The categories of third parties to which we sold PI, by categories of PI sold for each third party.

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.

Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.

You may alternatively exercise more limited control of your PI by instead exercising one of the more limited opt-outs, including unsubscribing from email newsletters.

We will revise this CCPA Privacy Notice from time to time as implementing regulations further develop and come into effect and we are able to provide you with better information on your CCPA rights and how to exercise them.

  1. Nevada Residents. Nevada residents have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. This site does not engage in activity that triggers the opt-out requirements defined in Nevada Revised Statutes Chapter 603A, beyond the purpose of the services offered on this site. However, you can exercise this right by contacting us at privacy@datalignadvisory.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. We will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
  2. Links to Other Websites and Third Party Practices. The Site may contain links to third party websites.  It is our intent to provide links only to other quality websites.  However, we have no control over these linked websites or, for that matter, any third parties.  Any information collected by websites, other than the Site, is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites that may be linked to or from the Site.  We encourage you to read the provisions of privacy policies on other websites before providing them with your personal information.

 

  1. Opting Out

If datalignadvisory.com sends emails to you, you may opt out of receiving such e-mails at any time by responding to the opt-out link provided on all such e-mail communications from datalignadvisory.com.

  1. Questions or Comments. If you have questions or comments about this Privacy Policy, please send us an email at privacy@datalignadvisory.com. If you prefer, you may also contact us via physical mail at:

Datalign Advisory, LLC

One Kendall Square, Suite B2102

Cambridge MA 02139